The taxpayer was not entitled to entrepreneurs’ relief on the disposal of an interest in an LLP, as the LLP had not traded in the relevant period prior to disposal.
A limited liability partnership (LLP) was established to acquire, construct, and operate a power plant in Hull using wood waste biomass as its fuel or feedstock. On 18 August 2015, the project in Hull was transferred to the LLP and the appellant became the owner of 14.65% of the partnership equity (1,465 membership units) in the LLP.
